Entry Capacity Substitution

1. Entry Capacity Substitution Workshop 4 9th July 2008 Entry Capacity Substitution Methodology Statement: Discussion Paper

2. Entry Capacity Substitution Methodology Statement • On 7th July 2008 National Grid issued a draft statement to the industry for comment. • This is NOT the formal consultation required under the Licence before seeking approval of the proposed statement from the Authority. • The formal consultation is anticipated to commence early September 2008. • Specific questions raised by National Grid to obtain views from interested parties • These questions follow………..

3. Discussion Paper: Question 1 • National Grid has interpreted the requirement to “minimise” the costs associated with funded incremental obligated entry capacity in this objective as meaning that all available capacity should be substituted to meet the incremental signal, without placing any restrictions on the substitution process. • The Entry Capacity Substitution objectives include: • ensuring that entry capacity substitution is effected in a manner which minimises the costs associated with funded incremental obligated entry capacity • Hence National Grid has developed the substitution methodology with no restrictions on the quantities available to be substituted. This could lead to significant quantities of capacity being substituted in year 1. • It may be argued that this is inefficient as “more economic” substitution opportunities may arise in subsequent years. • Conversely, later incremental signals may not occur and substitution opportunities would have been lost – and unnecessary investment made. • Notwithstanding the subsequent questions raised in this document, National Grid would welcome views on whether its interpretation is appropriate.

4. Discussion Paper: Question 2 • National Grid has taken the view that all incremental obligated entry capacity released must satisfy the NPV test detailed in the IECR. Substitution will only be considered if the test has been passed. However, National Grid would welcome views on whether a less stringent test should apply for the release of capacity that would, after analysis, be satisfied through substitution. • It should be recognised that whilst a different test could increase the quantity of incremental obligated entry capacity released it would add much complexity to Shipper bidding strategies, as National Grid would be unable to identify substitution opportunities in advance of the QSEC auction, and to National Grid’s assessment of substitution opportunities (e.g. need to identify a merit order for incremental requests where available capacity is limited; consideration of part investment, part substitution scenarios etc.).

5. Discussion Paper: Question 3 • The substitution obligation is to minimise funded incremental obligated entry capacity, which is released subject to a 42 month default lead-time. • Hence substitution will only be considered subject to a minimum 42 month lead-time (as may be adjusted according to the IECR). • Do respondents agree that it is appropriate to consider substitution opportunities consistent with the timing for the release of funded incremental obligated entry capacity? • It should be noted that any move away from the standard mechanism to release funded incremental obligated entry capacity will produce similar issues to those outlined in Q2, particularly in terms of increased complexity.

6. Discussion Paper: Question 4:a • This condition: • Capacity that is not offered for release in the Quarterly System Entry Capacity (QSEC) auctions, i.e. capacity that is held-back for MSEC auctions, will not be available for substitution between entry points. • limits the capacity available for substitution to 90% of the initial baseline quantity (10% being held back for MSEC auctions). It is not envisaged that this absolute quantity (i.e. GWh/day) will be reduced (within the current price control) to reflect capacity substituted from an ASEP. • National Grid would welcome views on whether it is appropriate for any restriction to be placed on the availability of capacity for substitution or whether the level not available should be increased (or decreased).

7. Discussion Paper: Question 4:b • If an increase is suggested then views on what this level should be and whether it would be justified in relation to the licence obligations would be appreciated. For example, National Grid has identified the following options for decreasing the amount of capacity available for substitution: • Increasing the percent of baseline with-held from QSEC auctions (requires a Licence change); • Setting a fixed percent of baseline that, although available for release in QSEC auctions, will not, even if unsold, be made available for substitutions; • Setting a fixed quantity (GWh/day) of capacity that will not be available for substitution from each ASEP; • Setting a fixed quantity (GWh/day / percentage) of capacity that will not be available for substitution from all ASEPs in aggregate; • Setting a maximum quantity (GWh/d or percentage) that can be substituted away at any ASEP. • In answering this question, National Grid would like respondents to express their views on: • Whether these approaches would be more efficient than maximising substitution from year 1? • What are the advantages and disadvantages of these actions? • Should such limits only apply for a limited duration, e.g. for years 1 [and 2], but be removed after experience of the first year of substitution? And if so how do respondents see substitution being phased in?

8. Discussion Paper: Question 5 • This paragraph: • Capacity will only be available to be substituted from an ASEP in the quantity in excess of the maximum aggregate allocation for any quarter from and after the quarter for which incremental capacity has been identified for release. • highlights the “single quarter” issue, whereby Shippers can “protect” capacity at an ASEP by booking capacity for a single quarter in a future year. National Grid does not propose any actions, at this time, to prevent Shippers making such capacity bookings. • Do respondents consider this to be appropriate or should action be taken to limit single quarter bookings in the future? if so what action is considered appropriate?

9. Discussion Paper: Question6 • Considering that the substitution process is identical within and out-with zones, do respondents feel that the use of zones is beneficial? • By dispensing with the within zone process the order in which donor ASEPs are identified may change slightly but may become less transparent.

10. Discussion Paper: Question 7 • In order to create an order for assessment of multiple recipient ASEPs National Grid is proposing Licence Revenue Drivers (LRDs) as the assessment criteria. • National Grid believes that the ASEP with the lowest LRD will facilitate more efficient substitution, i.e. less capacity needed from donor ASEPs. • Alternative criteria could be used and National Grid would welcome alternative proposals. • It should be noted that, in the absence of any constraints on capacity available for substitution, that if sufficient incremental obligated entry capacity is released, all available capacity, where beneficial, will be substituted regardless of the recipient ASEP order.

11. Discussion Paper: Question 8 • Do respondent favour an approach that requires National Grid to follow a set methodology or should National Grid have some discretion to select more favourable donor ASEPs?

12. Discussion Paper: Question 9:a • Following on from Q1, although the current draft methodology does not place any restriction on the quantity of capacity that can be substituted. National Grid would welcome views on alternative approaches and how these may better meet National Grid’s licence obligations. • These potential measures should be considered as a way of “managing” the use of substitutable capacity. This differs from, and is complementary to, the options in Q4, which limit the quantity of capacity available for substitution.

13. Discussion Paper: Question 9:b • Alternatives that National Grid believe merit consideration include (respondents may propose further alternatives); • An exchange rate cap. • It should be recognised that this option would not prevent all capacity being substituted away from a donor ASEP even with a 1:1 exchange rate cap. In the event that an exchange rate cap is considered appropriate: • how should the level be determined? What should be the level of an exchange rate cap? • Should a cap be applied in aggregate across all donor ASEPs or for each recipient/donor ASEP combination? • Are there any scenarios where different caps should apply?

14. Discussion Paper: Question 9:c • Limiting substitution to within zone only. • Although such a limit is likely to ensure that only reasonable exchange rates are generated it could also severely limit the scope for substitutions, particularly in zones with few ASEPs (e.g. Theddlethorpe, West UK zones): • Reducing all potential [within zone] donor ASEPs together by equal amounts (% or mcmd) instead of exhausting donor ASEPs in sequence. • It should be recognised that a sufficiently high level of signalled incremental capacity would still exhaust all potential donor ASEPs under this option. However, where all donor ASEPs are not exhausted the outcome would be sub-optimal substitutions, i.e. less favourable exchange rate overall. This option is also likely to be more complicated to undertake; an important issue considering the limited time that National Grid has to assess investment and substitution proposals.

15. Discussion Paper: Question 10 • As a transitional rule, substitution will not be considered in respect of “new ASEP specific auctions” where these auctions occur after implementation of this methodology and before a regular QSEC auction where capacity can be obtained at all ASEPs. • Do respondents agree with this transitional rule?

16. October Submission of Methodology Statement: Potential Timeline 1st Sept Commence formal consultation 13th October Submit ECS to Ofgem for approval 7th July Draft ECS issued. Fixed duration under Licence 28 plus 14 days 4th Aug 29th Sept Consultation on ECS (and IECR if required) Industry comments to NG NG review & redraft Draft report Potential Timeline 7th Aug Workstream 4th Sept Workstream 9th July Workshop 4

17. Next Steps • Next workshops • None scheduled • Informal consultation on draft ECS methodology statement. • Replies to National Grid by 5pm 4th August 2008. • To: • andrew.fox@uk.ngrid.com and • box.transmissioncapacityandcharging@uk.ngrid.com